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FDA Releases Draft Guidance on Plant-Based Food Labeling
Wednesday, January 8, 2025
  • On January 6, 2025, the U.S. Food and Drug Administration (FDA) released “Labeling of Plant-Based Alternatives to Animal-Derived Foods: Draft Guidance for Industry”, which provides recommendations on best practices for naming and labeling plant-based foods marketed as alternatives to animal-derived products.
  • The guidance covers plant-based alternatives to eggs, seafood, poultry, meat, and dairy products, excluding plant-based milk alternatives, which have their own draft guidance.
  • When labeling plant-based alternatives, the product name must be prominently displayed on the principal display panel (21 CFR 101.3).  The name can be a Standard of Identity (SOI) established by law or regulation, or in the absence thereof, a common or usual name, or an appropriately descriptive statement.  FDA has not established specific Standards of Identity for plant-based alternatives by law or regulation.  Further, many plant-based products use novel food ingredients without a common or usual name, and so are required to use a descriptive statement.
  • FDA recommends that plant-based products should (1) identify the plant source (e.g., soy, almond) and (2) clearly state that the product is not animal-based.  The source of the plant-based ingredients should be part of the name, rather than just stating “plant-based.” Omitting a predominant ingredient may be considered misleading.
  • The Draft Guidance includes several examples of best practices for labeling.  Some examples include the following:
    • If a plant-based alternative food includes the name of a standardized food, such as “cheddar cheese,” the SOI should be qualified by the plant source, such as “soy-based cheddar cheese.”
    • “Pork-less bacon” is insufficient as it does not distinguish between other plant-based alternative products.  “Plant-Based Soy-Bacon” would be a more appropriate name.
    • If a product has multiple plant sources, the predominant sources by weight should be included.  For example, a veggie patty containing black beans, mushrooms, and other vegetables with black beans as the predominant ingredient should be labeled as “Black Bean Mushroom Veggie Patties.”
  • To ensure the FDA considers them, comments on the Draft Guidance must be submitted within 120 days of its publication in the Federal Register, by May 7, 2025. 
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